ML20199F637
| ML20199F637 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 11/14/1997 |
| From: | Subalusky W COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-373-97-15, 50-374-97-15, NUDOCS 9711240282 | |
| Download: ML20199F637 (4) | |
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is l Hi s W 4.*b t November 14,1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Subject:
Notice of Violation; NRC Inspection Report 50 373/374 97015 LaSailo County Station, Units 1 and 2 Facility Operating Licenso NPF 11 and NPF 18 NRC Dacket Nos. 50 373 and 50 374
References:
M. N. Loach lotter to W. T. Sobalusky, dated October 20,1997, Transmitting NRC Inspection Report 50 373/374 97015 The enclosed attachment contains LaSallo County Station's response to the Notice of Violation, that was transmitted in the Reference letter.
If there are any questions or comments concerning this letter, please refer them to me at (815) 357-6761, extension 3600.
Respectfully,
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,gy W. T. Subalusky Site Vice Prepkfifnt 1
LaSallo County-Blet' Enclosure
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cc:
. A. B. Beach, NRC Region lil Administrator M. P. Huber, NRC Senior Resident inspector LaSalto D. M. Skay, Project Manager - NRR - LaSalle
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 373/374 97015 VIOLATION: 373/374 97015-01 i
During an NRC in':pection conducted on September 8 through September 12,1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
Technical Specification 3.5.2 required that at least two of the following shall be operable when the plant is in operational condition 4 or 5:
a, low pressure core spray system t
b.
Iow pressure coolant injection (LPCI) subsystem 'A' of the residual heat removal (RHR) system c.
LPCI subsystem 'B' of the RHR system d.
LPCI subsystem "C" of the RHR system e.
the high pressure core spray system Technical Specification 3.5.2, Action b, required that with both of the above required subsystems / systems inoperable, suspend CORE ALTERATIONS and all operations that have a potential for draining the reactor vessel.
Restore at least one subsystem / system to OPERABLE status within four hours or establish SECONDARY CONTAINMENT INTEGRITY within the next eight hours.
Ccntrary to the above, on September 4,1997, all of the above systems were inoparable and the licensee was unable to restore one subsystem / system within four hours or establish secondary containment integrity within the following eight hours.
This is a Severity Level IV violation (Supplement 1) (50 373/97015 01).
REASON FOR VIOLATION: 373/374-97015-01 The station standard during outage activity has been to meet the minimum Technical Spocification requirements, while relying on the shutdown risk (SDR) program to warn of configurations that could challenge plant safety during shutdown conditions. This has led to developing outage plans which did not take a sufficiently conservative approach to Technical Specification compliance.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The 1 A DG Control Room Frequency Meter (ISI DG028) was replaced and surveillance LOS DG M2 repeated with satisfactory results allowing restoration of 1 A DG and *B" and "C" RHR (LPCI) operability.
A Senior Manager on Shift Progiam has been implemented and is used to sharpen the plant's focus on safety and Technical Specification compliance.
Senior managers are assigned shift oversight duties at the discretion of the Plant Manager, Operations Manager or Shift Operations Supervisor.
CORRECTIVE STEPS TO BE TAKEN TO AVOID FURTHER VIOLATIONS:
Conservativo decision making expectations have been reviewed with i
Operations. The aspect of those expectations contained in Opa ations i
Memo No. 2 (LaSallo Operating Dopartment Vision) will be reemphasized with the Operating Department (NTS 373180 97 SCAOOOO32.01) during continuing training, which will be completed by June 1,1998.
By November 25,1997, Quality and Safety Assessment will assess the oversight of conservativo maintenanco planning for forced outages and take appropriato correctivo actions as an additional barrier against non-conservativo plans of the typo that led to this ( !ent.
(NTS 373180 97 SCAOOOO32.02).
The Plant General Manager has provided guidance on maintenance planning in Policy Guidelino No. 97 (Rov. O,9/30/97) specifying that the otation will comply with Technical Specifications, follow Shutdown and On lino Risk Guidelinos and avoid single failuro situations which prevent compliance with a Technical Specification.
Specifically, the plant will avoid planning activities which would result in non complianco with a Technical Specification Action Statement. Where circumstances provent const.vativo planning as discussed above, the issue will be raised to tho Plant Manager for consideration and resolution.
Procedures and guidelines used in work scheduling preparation (outage and non outage) are being revised. The revisions will provide for:
Dotormination cf situations where a single failure would prevent complianco with a Technical Specification Action Statement and directing the attention of the Plant Manager to the issuo for resolution.
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Assignment of responsibility for review of proposed work window with respect to its impact on Technical Specification and Conservative Decision Making in maintenance planning.
i Documentation of such single failure Technical Specification e
challenges in writing to the Shift Manager, i
Outage guidelines were completed on October 31,1997. Non outage e
guidelines will be completed by February 1,1998.
(NTS 373180 97 SCA000032.04)
Changes to LAP 100 47," Shutdown Risk Management" and Shutdown Risk Guidelines for Units 1 and 2 will be completed by February 1,1998. (NTS 373180 97 SCAQ00032.05)
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
i Full compliance was achloved on September 5,1997.
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